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Interpretation ID: GF003147

    Kenneth M. Bush, Associate Director
    Government Relations
    American Suzuki Motor Corporation
    3251 East Imperial Highway;
    PO Box 1100
    Brea, CA 92822-1100


    Dear Mr. Bush:

    This responds to your letter in which you ask about the procedures the National Highway Traffic Safety Administration (NHTSA) would follow for locating "Point 1" described in S10.1(a) of Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant protection in interior impact. You provide an illustration and two different interpretations of these procedures.

    By way of background, FMVSS No. 201 requires that vehicles meet certain performance criteria when specific targets in the interior are struck by an instrumented headform representative of a human head. When NHTSA performs compliance testing, it does so in accordance with testing procedures specified in FMVSS No. 201. With respect to targets located on the A-pillar, the agency would perform testing using the target location procedure in S10.1.

    In order to locate "Point 1" described in your letter, the agency would follow the following procedure described in S10.1(a):

    "On the vehicle exterior, locate a transverse vertical plane (Plane 1) which contacts the rearmost point of the windshield trim. The intersection of Plane 1 and the vehicle exterior surface is Line 1. Measuring along the vehicle exterior surface, locate a point (Point 1) on Line 1 that is 125 mm inboard of the intersection of Line 1 and a vertical plane tangent to the vehicle at the outboardmost point on Line 1 with the vehicle side door open"

    NHTSA locates "Point 1" by measuring inboard, along the nominal vehicle exterior surface, 125 mm from the intersection of "Line 1" and the outermost edge of the roof, with the door open. "Line 1" is established by locating a transverse vertical plane (Plane 1) that is perpendicular to the vehicle longitudinal plane, which contacts the rearmost point of the windshield trim. We note that the outermost edge of the roof is determined with the door open and includes uncompressed weather stripping, rain gutter, or other trim components. NHTSA makes linear measurements following the nominal vehicle surface (as opposed to following each convolution of weather stripping, rain gutter or other trim components). See Laboratory Test Procedure for FMVSS No. 201U (TP-201U-01, April 3, 1998, pages 37 and 38 at www.nhtsa.gov), and the enclosed illustration.

    In your letter and accompanying illustration, you offer two interpretations for the location of "Point 1." The difference between the two interpretations appears to stem from the location of the outboardmost point on Line 1; i.e., the intersection of Plane 1 and the vehicle exterior surface. As explained above, that intersection is located at the outermost edge of the roof, with the door open. After examining your illustration, we believe that this intersection is marked "point *2."

    If you have any further questions, please feel free to contact George Feygin of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    Enclosure
    ref:201
    d.7/14/05

TARGET AP1 (A-PILLAR REF. APR)